Torch (“we”, “our” or “us”) is committed to protecting your personal data and complying with data protection laws. Please read this privacy policy carefully. It provides information about how we use personal data and the rights available to you under data protection laws.
1. Layered Approach
We use a layered approach to delivering information about data protection through:
A brief privacy notice in insurance policy documentation when we issue your policy, which will refer to this more detailed privacy policy;
This privacy policy accessible online;
The London Market Core Uses Information Notice. This Notice provides further information on how personal data is used within the insurance market.
2. Information we may collect about you
We may collect and process the following personal data about you:
Information provided to us through enquiry, application or claims forms, including:
information such as your name, address or contact details;
sensitive information (e.g. details of any criminal or fraudulent behaviour or medical information) obtained either through you or third parties;
we may maintain records of any correspondence with you including phone records;
information we collect through cookies. Please see our cookies statement for further information, an example cookies policy can be found in Appendix 4.
3. Why we collect personal data
We are required by data protection laws to have a legitimate reason to process and use your personal data. The main purpose for processing your personal data is for the provision and performance of an insurance contract e.g. reviewing your application, setting you up as a policyholder, administration and maintenance of your insurance policy or in order to process a valid claim.
With regards to ‘Special Category’ data i.e. sensitive information, we must obtain your consent at the point of collecting your personal data (i.e. when you input your details online or when completing a form) in order to process the data unless an exemption for insurance purposes is applicable. In some circumstances, if we do not have your consent to process your data, it may impact our ability to issue you with insurance cover or to handle any claims.
We may also gather personal data for the following purposes:
in order to prevent, identify and investigate fraud or any activity that is in the public interest;
to defend ourselves against or make any legal claims;
where we have lawful purpose for processing your data e.g. for maintaining our accounts and records, gathering market intelligence in order to develop and improve our products and services. We will ensure that the processing of your personal data does not affect your rights under applicable data protection laws;